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cr C O M M U N I T Y REINVESTMENT forum | WINTER | 2004 PUBLISHED BY THE FEDERAL RESERVE BANK OF CLEVELAND Individual Development Accounts: An Endangered Wealth-Creation Strategy? The introduction of the Individual Development Account (IDA) in 1996 opened the door to a new school of thought on ending the cycle of poverty. This innovative tool challenged traditional means of support by asking the question, What if we can do more good for more people by helping them actively save and build assets than by simply offering cash assistance? Since then, IDAs have become wildly popular among low-income individuals and families. But can funding keep pace with demand? CONTINUED ON NEXT PAGE AN EXCHANGE OF COMMUNITY DEVELOPMENT ISSUES AND IDEAS 4th District Profile 4 In My Opinion Compliance Corner Reader’s Survey Canton, Ohio: Home to One of the Nation’s Leading IDA Programs Overcoming Funding Challenges IDAs and CRA Tell us what you think! 6 8 9 CONTINUED FROM PAGE 1 T he idea was straight- forward: Strengthen the economic stability of low- | COMMUNITY REINVESTMENT FORUM 2 income individuals, families, and communities by offering them incentives to save for lifechanging assets – namely “Similar to 401(k)s, IDAs help low-income families build the financial assets — homes, businesses, education — that they need to achieve the American dream. Small investments in matched savings and personal finance education can yield big returns for families, financial institutions, communities, and the nation.” homeownership, small business - Corporation for Enterprise Development (CFED) start-up, or post-secondary education. Their deposits into Individual Development Accounts (IDAs) would be matched by private and/or dollar amount specified on a program-by-program basis. Add to the mix financial literacy education and training, and clearly, the IDA concept held great potential. Private and Public Support Foundation-funded commu- efforts include the following: • The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 • The Assets for Independence Act of 1998 • The establishment of an IDA program for refugees by the Office of Refugee communities, with the hope Columbia have passed laws that their outward display of to support IDAs (34 actually • The Savings for Working support would leverage have programs in place), and Families Act (SWFA) significant public funding. legislation has been introduced public funding at a rate of 1:1 to 7:1, to a maximum to support IDAs. Notable federal Typically a bit more in most of the remaining states. Resettlement Additionally, the Affordable cautious, policymakers waited State policies have helped to Housing Program (AHP) of to see if low-income people create funding streams for IDAs the Federal Home Loan Banks, could and would actually save. and generate federal support. Bank Enterprise Awards of It didn’t take long for them to see that the answer was a resounding yes. IDA partici- the Community Development O n the federal level, Financial Institutions (CDFI) Fund, Family Self-Sufficiency pants were plentiful, as they a number of IDA proposals Program, HOME Investment welcomed the new opportunity have been considered over the Partnership Program, U.S. for building wealth. Today, past eight years, and a variety Treasury Electronic Trans- 29 states and the District of of programs have been initiated action Accounts, IDA VISTA nity organizations enthusiastically embraced the IDA concept. They committed funding, manpower, and creative resources to the development and implementation of IDA programs in their “We know we must bring to the table a high level of support in terms of offering strong savings products to IDA accountholders, providing quality service, and reporting responsibly to our nonprofit partners.” - James Matthews Senior Vice President Corporate Community Reinvestment Manager National City Special thanks to the Corporation for Enterprise Development (CFED), as well as to the following individuals, for generously sharing information and insights into IDA programs and policies for this issue: George Barany Executive Director WECO Fund, Inc. email@example.com wecofund.com Ray Boshara Director, Asset Building Program New America Foundation Boshara@newamerica.net newamerica.net Inger Giuffrida Director Assets Alliance firstname.lastname@example.org assetsalliance.org Monica Graves Assistant Vice President and CRA Officer Unizan Bank email@example.com unizan.com Inna Kinney Executive Director Economic Community Development Institute firstname.lastname@example.org James Matthews Senior Vice President Corporate Community Reinvestment Manager National City email@example.com nationalcity.com Jay Murdock Executive Director Stark County Out of Poverty Partnership firstname.lastname@example.org scopp.org Kim Pate Director of Field Development Corporation for Enterprise Development (CFED) cfed.org nancial institutions, financial support IDAs in various ways. services firms, community Financial Services Partners development financial insti- In addition to holding the tutions, foundations, and potential to be generous inves- philanthropic organizations tors in IDA programs, financial continue to make socially institutions play a pivotal role responsive investments into this in providing account manage- asset-building effort,” says ment services. But they are Kim Pate, director of field careful in choosing their IDA development for CFED. “How- partners. They want to be ever, adding to this funding sure they are associated with terms of offering strong savings base requires demonstration programs that succeed in products to IDA accountholders, of the incentives for becoming helping their clients achieve providing quality service, and involved. For example, their homeownership, educa- reporting responsibly to our supporting IDAs provides an nonprofit partners.” opportunity for positive public tion, or small business goals. relations: Those who back J The Outlook for IDAs these programs can enhance ames Matthews, senior Despite their growing popular- their activities in low-income vice president and corporate ity – more than 500 programs communities and develop community reinvestment man- nationwide are supporting partnerships with other stake- ager for National City, explains 20,000 active accountholders, holders. These investors may what his bank seeks in an according to the Corporation also receive recognition for IDA partner: “We look at the for Enterprise Development their efforts from the Commu- strength and capacity of the (CFED) – and the initial surge nity Reinvestment Act (CRA) provider organization. Do they of support IDAs enjoyed, and other community develop- have the capacity to deliver the private and public support is ment programs.” (For more program? Has their program beginning to wane. Nonprofits information on the benefits to actually helped people change are finding it increasingly investors, see In My Opinion, their behavior, and is that difficult to locate match dollars pages 6-7.) change demonstrated through as well as operating funds. monthly saving habits?” Matthews, who is based in Pittsburgh, has been involved in the IDA effort since its inception. He points out that it is equally important for the partner financial institution to have solid credentials. “We know we must bring to the table a high level of support in CONTINUED ON PAGE 11 | Darrick Dansby Executive Director SMART Money email@example.com smart-money.org any private fi- America), and other programs COMMUNITY REINVESTMENT FORUM Ann Bailey Executive Director Action Housing ABailey@actionhousing.org actionhousing.org “M (Volunteers in Service to 3 4th district Canton, Ohio: Home to One of the Nation’s Leading IDA Programs | COMMUNITY REINVESTMENT FORUM profi 4 “Typically, society spends about $20,000 a year to maintain a family in poverty in government welfare-type programs. Our organization spends $4,000 to move a family beyond income maintenance programs to build wealth and get out of poverty.” Jay Murdock Executive Director Stark County Out of Poverty Partnership (SCOPP) Jay Murdock’s inspiration about Individual Development Accounts (IDAs) came one morning in 1995 while he was watching TV. The show was a housing conference sponsored by former U.S. Housing and Urban Development Director Jack Kemp. Cicero Wilson of the Corporation for Enterprise Development (the national IDA association) described how IDAs could help low-income families build wealth. Murdock, then the housing director for the Stark County Out of Poverty Partnership (SCOPP), was immediately sold. He saw IDAs as a way to augment the organization’s Family Development Program, which lacked a financial services component. “We were helping families overcome social barriers but not financial ones,” Murdock recalls. “After Cicero Wilson spoke, I knew that our organization needed to create an IDA program to help families overcome income and credit issues.” In 1999, the program was launched with local support from Unizan Bank. Now, Murdock is the organization’s executive director. Family Development Program Explained SCOPP, formed in 1991, created its IDA program as a way to serve the needs of low- and moderate-income families in the city of Canton and Stark County, Ohio. Called the Family Development Program, the IDA offers a way to increase savings and investments for low-income families. This program couples economic literacy training with a financial incentive to save for the acquisition of an asset. Program participants learn about budgeting, savings and investments, banking and credit. While they receive this training, they also save for one of the following life goals: a down payment on a home, establishment of a small business, or college education. For every $1 they save, SCOPP provides $4 in matching funds – one of the highest matches in the nation. Match funds for the IDA come from the U.S. Department of Health and Human Services and local foundations. While SCOPP has longstanding relationships with many lenders in town, Unizan Bank plays the most prominent role. Since day COMMUNITY REINVESTMENT FORUM le “My business has changed my life because I’m in a position to meet new people and control my own destiny. one, Unizan Bank (formerly United National Bank) has held the accounts and provided operating support. “I think it’s an excellent program,” explains Monica Graves, assistant vice president and CRA officer for Unizan Bank. “SCOPP and its board of directors believe in the assetbased theory prescribed by Brian Grossman, Robert Friedman, and Puchka Sahay that couples financial literacy programs with monetary rewards to break the cycle of generational poverty. Jay Murdock and [Program Manager] Sharon Nunn-Alexander have done a great job.” As a result, Unizan recently received the CRA and Fair Lending Colloquium’s annual Community Impact Award for its work with SCOPP. Success Stories Currently, 46 people are enrolled in the SCOPP’s Family Development Program at different levels of participation. Another 15 are coming on line. While homeownership is a goal, the participant’s IDA funds can also be used to start a business or go to of satisfaction.” Sherry Morgan Owner of Quick Cupid school. Most importantly, SCOPP’s IDA program gives people a new outlook on life. The program’s manager, Sharon Nunn-Alexander, is a stalwart champion of the Family Development Program, not only because she is the administrator but also because she successfully participated in the program herself. “I benefited from SCOPP’s Family Development IDA Program as a result of my enrollment in 1999,” Nunn-Alexander explains. She faithfully saved a portion of her earned income to invest in the IDA’s match account so she could put a down payment on her first house. Soon after, Murdock hired her to run the program. “I feel that my story is a testimony of what this program can do to change other people’s lives as it did mine,” Nunn-Alexander remarks. Murdock adds: “We’re very proud of our graduates.” Thomas Williams enrolled in the SCOPP’s IDA program to start his own entertainment business, Finesse Entertainment. But that wasn’t his only motivation. After 25 years of working nights and weekends on video and sound production for a television station, Williams decided it was time to go solo. “Now, I can freelance from home and spend more time with my children,” says the proud father of a 16-year-old son and 15-year-old daughter. Sherry Morgan used SCOPP’s IDA program not only to purchase her first house but also to start her own “speed dating” service, called Quick Cupid. “I give singles an opportunity to get together and let God do the rest,” she says. “A few people are already getting married.” | It gives me a great sense Morgan used some of her funds from her IDA to buy Web site rights, computer equipment and office supplies. Since May, Quick Cupid has prospered. “My business has changed my life because I’m in a position to meet new people and control my own destiny,” Morgan testifies. “It gives me a great sense of satisfaction.” Murdock views the IDA program as a good return on investment. “Typically, society spends about $20,000 a year to maintain a family in poverty in government welfaretype programs,” he explains. “Our organization spends $4,000 to move a family beyond income maintenance programs to build wealth and get out of poverty. That’s a better investment of resources than government poverty programs.” What does success look like for SCOPP? According to Murdock, “Success would be to continue to see families purchase leverageable assets – businesses, homes, education – and move toward economic independence. As an organization, we would like to expand upon what we are currently doing and have the staff capacity to do it.” 5 in my | COMMUNITY REINVESTMENT FORUM 6 opin Overcoming Funding Challenges BY INGER GIUFFRIDA Financial Educator/Asset-Building Strategies Consultant Director of the Assets Alliance In the past couple of years, practitioner organizations have been struggling to secure adequate funding for Individual Development Account (IDA) initiatives. In the 1990s, IDA programs had the benefit of being a new strategy for wealth creation for the poor. Today, as more than 20,000 Americans have participated in IDA programs, this strategy is no longer viewed as innovative or cutting edge among many institutions and individuals with the resources to provide financial backing. State and federal budget cuts add to the funding challenge. Evaluation data indicate that IDAs do work, however. People who had never had relationships with financial institutions now hold accounts. People for whom budgeting was a foreign concept have completed financial literacy courses. People who thought they could only dream of owning a home, starting a business, or getting education to start a new profession have realized their highest ambitions. Yet thousands of lowincome families still have not been reached by IDA programs. The potential market and the potential for long-term positive effects far exceed the supply of opportunity. Many prospective funders balk at some of the expenses associated with IDA programs. In addition to the costs of managing a matched savings account are those associated 2 with recruiting, assessing, enrolling, educating, and supporting accountholders. In this funding environment, demonstrating and communicating results – the social, psychological, and economic benefits resulting from IDA programs for individuals, families, and communities – become critical to generating financial resources. Organizations should consider the following five strategies to ensure that their IDA programs are adequately resourced: 1 Reduce Program Costs Link with an existing IDA program that has a cost-effective administrative infrastructure (policies, procedures, account management, data collection) in place. Outsource program components to organizations that specialize in key areas: financial education, credit counseling, microenterprise development training and technical assistance, educational and career planning, homebuyer education, home maintenance education. Integrate IDA program processes and components with existing organizational infrastructure. For example, if an organization has a case manager specializing in intake for agency programs, incorporate assessment and intake into the IDA program. Remunerate and support IDA program staff adequately to avoid turnover. Staff turnover leads to higher attrition and agency costs, and lower program productivity. Increase Program Revenue Identify funding sources interested in intermediate or corollary outcomes embedded in IDA program outcomes – e.g., increased financial literacy rates, increased homeownership rates, increased business ownership, improved credit scores. Identify and communicate benefits of investing in an IDA program specific to each potential funder. For example, the benefits of supporting an IDA program for a financial institution might include reaching new markets, developing long-term relationships with new customers, providing employees with a volunteer 5 will serve. Some individuals may be more valuable for influence on potential funders than as funders themselves. Use statistics and success stories (if your program is a start-up, borrow success stories from other communities) in a variety of media (newsletters, newspapers, journals, speeches, public access television, radio programs) to communicate the potential of IDA programs. Promote milestone achievements of accountholders and the IDA program through media and special events. For example, when a group completes the financial education course, hold a public graduation ceremony and invite stakeholders, opinion leaders, and decision-makers. Ask service organizations if you can speak at their meetings. Use success stories and statistics to develop a compelling story, and bring an accountholder to share her/his story first-hand; distribute brochures, flyers, bookmarks, fact sheets, or business cards. Ensure systems are in place to follow up with individuals and organizations that express interest in the IDA program. 34 Implement a Relevant External Communications Strategy Identify potential stakeholders, opinion leaders, and decision-makers in the community your IDA program Demonstrate Outcome Attainment It is easier and cheaper to keep a funder than get a new one. Demonstrate that their investments have produced results — economic, social, and civic results, as well as psychological results for accountholders and their families. Set up systems to collect data to demonstrate attainment of these results. Link IDAs With Other Assetbuilding Strategies Asset building has come to connote a broad array of policies and initiatives designed to help families with low income and low wealth access and maintain financial and long-term, productive assets. In addition to IDAs, here are some strategies commonly associated with asset building: • Savings mobilization • Tax credit access and tax return preparation with an emphasis on the Earned Income Tax Credit (EITC) • Broad-based financial literacy education • Employer-based asset building • Small business development or expansion • Homeownership • Human capital development IDAs can be effectively linked with any of these strategies, resulting in a synergy that increases the efficacy of the IDA program as well as the other asset-building strategies. This, however, should be done only if the additional asset-building strategies are truly beneficial to the IDA program’s target markets. While there are no easy answers with respect to IDA program funding, a multi-faceted strategy that involves more than searching foundation databases for potential funders and writing proposals is necessary to develop new IDA initiatives or to sustain established IDA programs. The Assets Alliance is a membership organization of experienced professionals from the IDA and asset-building fields. The organization is dedicated to expanding the number of individuals and families participating in IDAs and asset-building opportunities by advancing communications and sharing effective practices, resources, and tools with the field and among technical assistance providers. For more information on developing effective resource strategies for an IDA program, contact Inger Giuffrida at firstname.lastname@example.org or visit the Assets Alliance Web site: www.assetsalliance.org. | opportunity, and contributing to the stabilization of the community through the development of new homeowners, new business owners, and a more highly trained workforce. Start fund-raising efforts locally. Benefits for funders investing in their own communities are direct and immediate. Consider community foundations, corporations with a presence in the program service area, financial institutions, service organizations, faith-based organizations, educational institutions and individuals. Articulate and demonstrate how supporting IDAs complements their missions and priorities for investing. Use these local sources to leverage regional, state, and federal funding. Communicate short-term, intermediate, and long-term program outcomes to potential funders. Consider charging participants fees. Building on the notion that people value things for which they pay, programs could charge a program application fee, fees for financial education, and fees for asset-specific training. COMMUNITY REINVESTMENT FORUM ion 7 corner compliance | COMMUNITY REINVESTMENT FORUM 8 IDAs and CRA While no standard program exists, Individual Development Accounts (IDAs) generally take the form of deposit accounts designed to help low- and moderateincome individuals or families accumulate savings for a number of purposes. The accounts are used for generating savings for education or job training, down payments or closing costs for the purchase of residences, or start-up capital for Paul E. Kaboth Assistant Vice President Federal Reserve Bank of Cleveland small businesses. The greatest benefit of IDAs to the participant is that once he or she has successfully funded the IDA, matching funds are added by a public or private entity. Depending on the nature of an institution’s efforts, its participation in IDAs may qualify under lending, investment, or service tests for Community Reinvestment Act (CRA) evaluations. In evaluating efforts, examiners look at both the level and nature of the involvement. For example, if an institution’s involvement is, either directly or indirectly, in the design and implementation of an IDA program, the examiner will consider such efforts under Depending on the nature of an institution’s the service test. The extent of the services offered, such as retail efforts, its participation in IDAs may banking services associated with, qualify under lending, investment, or service or financial education offered in tests for Community Reinvestment Act (CRA) evaluations. conjunction with, the accounts would be considered with other services offered by the institution. If an institution matches participants’ IDA contributions or donates funds to an entity that matches contributions, the level of contributions would be considered along with other investments and contributions under the investment test. Clearly, a crucial aspect of an institution’s involvement with an IDA program would be a strong partnership with a public or private entity that promotes this developmental opportunity. While they are a relatively recent development, IDAs offer institutions an opportunity to expand the portfolio of institutional investments or services offered as part of CRA. Financial institutions can ill afford to ignore IDAs as a tool for reaching low- and moderate-income customers as well as underserved areas within their markets. cr C O M M U N I T Y REINVESTMENT forum Make CR Forum your publication! Tell us what you like, what you don’t like, how you’d prefer to receive it, and how we can make it even better for you by completing this very brief survey. 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Please enter your contact information: Name_____________________________________________________ Title______________________________________________________ Organization________________________________________________ Address____________________________________________________ __________________________________________________________ Email address_______________________________________________ Phone________________________ Fax_________________________ Any additional comments?______________________________________ _________________________________________________________ fold here NO POSTAGE NECESSARY IF MAILED IN THE UNITED STATES BUSINESS REPLY MAIL FIRST-CLASS MAIL PERMIT NO. 8220 CLEVELAND, OHIO POSTAGE WILL BE PAID BY ADDRESSEE FEDERAL RESERVE BANK OF CLEVELAND PO BOX 6387 CLEVELAND, OH 44101-1387 COMMUNITY AFFAIRS DEPARTMENT tape closed here CONTINUED FROM PAGE 3 CR FORUM Maria J. Thompson, Senior Advisor & Managing Editor Dan Holland, Senior Advisor & Contributor Emma Petrie, Research Analyst & Contributor CLEVELAND Ruth Clevenger Vice President and Community Affairs Officer 216/579-2392 email@example.com Cassandra McConnell Community Affairs Manager 216/579-2474 firstname.lastname@example.org Maria J. Thompson Senior Advisor 216/579-2903 email@example.com Paula Warren Administrative Assistant 216/579-3111 firstname.lastname@example.org The American Dream Demonstration: Research Makes the Case for IDAs The American Dream Demonstration (ADD), organized by CFED in 1997, was a five-year test of IDAs as a social and economic development tool for low-income communities. ADD brought together 13 community-based organizations to design, implement, and administer IDA initiatives in their communities. Three years later, the Dream team had established well over 2,000 IDAs. ADD programs and accountholders became the subjects of ongoing research that ultimately proved that (1) low-income individuals can save, and (2) access to an IDA program improves savings and asset accumulation, particularly in the area of homeownership. (For more information, visit idanetwork.org.) every American with a savings account at birth. Each individwith low-income individuals F ual would begin with $500, | Emma Petrie Research Analyst 216/579-2236 email@example.com An Endangered Wealth-Creation Strategy? 11 eligible for an additional $500 rom the standpoint of America Foundation and at birth and the opportunity to public funding, passage of the author of Individual Develop- earn matching funds until age SWFA, which would authorize ment Accounts and Public 18, at which point the account a tax credit to investors that Policies to Build Savings and would become a Roth IRA, support IDAs through matching Assets for the Poor (published offering opportunities for Jeff Gatica Senior Advisor 513/455-4281 firstname.lastname@example.org funds, would certainly get by Brookings Institution; visit education, homeownership, and the ball rolling, but it would www.brookings.edu/WRB). retirement security that the Candis Smith Community Affairs Advisor 513/455-4350 email@example.com Boshara, director of the Asset and look at larger efforts — Building Program at New larger, more ambitious policies CINCINNATI only be the start, says Ray “We need to expand IDAs and policies that address both PITTSBURGH Dan Holland Senior Advisor 412/261-7947 firstname.lastname@example.org Visit us on the World Wide Web www.clevelandfed.org We welcome your comments and suggestions. Send them to email@example.com The views stated in Community Reinvestment Forum are those of the individual authors and are not necessarily those of the Federal Reserve Bank of Cleveland or of the Board of Governors of the Federal Reserve System. Materials may be reprinted provided the source is credited. Please send copies of reprinted materials to Community Affairs, Federal Reserve Bank of Cleveland, P.O. Box 6387, Cleveland, Ohio 44101-1387. COMMUNITY REINVESTMENT FORUM Please contact the following members of the Community Affairs staff if you have questions or would like additional copies of this publication. Individual Development Accounts: “Asset owners may spend less time cycling on and off various publicassistance programs and more time as wage earners, consumers, and productive members of the state’s economy.” - CFED State Asset Development Report Card long- and short-term savings middle and upper classes have enjoyed for years. “I DAs are the success- needs of low-income individ- ful down payment on the uals and families,” Boshara broader vision for helping low- says. “The federal government income people save and accum- has structured and subsidized ulate assets,” Boshara concludes. savings strategies for the non- “They have put savings and poor [such as IRAs and 529 asset-building strategies on plans]; now it needs to do the the map. But we also need to same for the nation’s poor.” recognize that going forward, By way of example, Boshara we need larger policies that will cites the Aspire Act (www. help us get to scale … that will AspireAct.org), which would help end the cycle of poverty create a structure for providing and restore hope, confidence, and economic opportunity to our nation’s poor.” of interest New Markets Tax Credit: “Making the Deal” January 25, 2005 Cincinnati, Ohio Federal Reserve Bank of Cleveland Contact: Candis Smith Community Affairs Advisor 513/455-4350 firstname.lastname@example.org April 7-8, 2005 The Capital Hilton Washington, D.C. Federal Reserve System’s Fourth Community Affairs Research Conference Contact: Ruth Clevenger Vice President and Community Affairs Officer 800/433-1035 email@example.com Financial Education Conference & Consortium Meetings June 2005 Cleveland, Ohio Federal Reserve Bank of Cleveland Contact: Jeffrey Gatica Senior Advisor 513/455-4281 firstname.lastname@example.org Cleveland, Ohio Consortium Meetings & Fall 2005 Financial Education Conference Contact: Maria J. Thompson Senior Advisor 216/579-2903 email@example.com Regulatory Roundtables Fair Lending Cincinnati, Ohio – proposed: May Pittsburgh, Pennsylvania – October/November Investment Test Lexington, Kentucky – May Akron/Canton, Ohio – September Toledo, Ohio – September Wheeling, West Virginia – October/November Contact: Candis Smith Community Affairs Advisor 513/455-4350 firstname.lastname@example.org Details about 2005 planned programs and workshops are posted regularly to the Community Affairs Office Web page at www.clevelandfed.org/commaffairs. Cincinnati & Dayton, Ohio Consortium Meetings Contact: Candis Smith Community Affairs Advisor Cincinnati Office 513/455-4350 email@example.com Pittsburgh, Pennsylvania Consortium Meetings Contact: Dan Holland Senior Advisor Pittsburgh Office 412/261-7947 firstname.lastname@example.org Publications CDFI Industry Highlights The Coalition of Community Development Financial Institutions recently released updated snapshots of CDFI industry accomplishments in all 50 states and the District of Columbia. You can access the new fact sheets at www.cdfi.org/stateprof.asp. FEDERAL RESERVE BANK OF CLEVELAND P. O . B O X 6 3 8 7 FIRST CLASS MAIL CLEVELAND, OHIO 44101-1387 US POSTAGE PAID CLEVELAND, OHIO PERMIT NO. 385 | Promises & Pitfalls: As Consumer Options Multiply, Who is Being Served and At What Cost? 2005 Community Development Policy Summit COMMUNITY REINVESTMENT FORUM Workshops 2005Programs + 12